Condemned by Law: Assassination of Political Dissidents Abroad

rejecting extradition requests based on the political offense exception.17 The prevalence of attentat clauses in extradition treaties illustrates the degree to which assassinations are universally condemned by the international community.18

A survey of domestic legislation also reveals a long-standing prohibition on assassinations.19 Courts in the United Kingdom (U.K.) and the United States (U.S.) have shown particular sensitivity to the practice of state-sponsored assassinations.20 Courts in the U.K. have consistently convicted and upheld harsh criminal sentences applied to conspirators of assassination plots.21 United States courts have adopted a similar view. Some of these rulings were issued pursuant to federal and state criminal laws specifically prohibiting the planning and execution of assassinations, murders and other acts of political violence on U.S. territory.22 Others were based on various civil laws23 holding foreign officials and states liable for damages resulting from the assassination of government officials committed on foreign soil.24 These decisions have not been limited to the targeting and unlawful killing of government officials alone. For example, after the 1980 assassination of political dissident Ali Akbar Tabatabai in Maryland, USA, Tabatabai’s assassin, Daoud Salahuddin, was charged by U.S. authorities with murder and unlawful flight after escaping to Iran.25 Though the U.S. has not been able to try Salahuddin himself, several of his accomplices were charged with, inter alia, driving the getaway car and disposing of the murder weapon.26 More recently, a U.S. district court awarded $12 million in compensatory damages to the family of murdered dissident Dr. Shapour Bakhtiar.27 The civil suit was filed